The nation's first coal gasification-liquefaction plant is proposed for construction in northeastern Pennsylvania, where the plant will use waste coal to produce 40 million gallons of clean-burning diesel fuel each year. Other state-of-the-art waste coal power plants are helping to power the state's economy by putting to use an energy source that otherwise would be a threat to the environment and a hazard to our health.

With encouragement and support from the state, coal mine methane is being captured and used for fuel rather than simply being vented into the air and wasted. Not only are projects like this a boon to the environment, but with record-high natural gas prices, this new fuel source benefits our economy as well.

All of these innovative projects illustrate that industry goals and environmental goals are not mutually exclusive. We can work together to protect the environment and provide economic gains. Yet, while the governor is working to promote clean coal in Pennsylvania, the U.S. Environmental Protection Agency is pushing a mercury reduction rule that would result in a very real and significant economic dislocation for the state's coal industry.

The federal rule encourages "fuel switching" because it requires little or no reductions from units using sub-bituminous coal mined in the West and places the most stringent requirements on coal mined in Pennsylvania -- a feature that is contrary to achieving maximum mercury reduction.

Bituminous coal generally contains more mercury than sub-bituminous coal. But it also contains more chlorine, and chlorine enhances the removal efficiency of mercury control technology. So, controlled bituminous coal is "cleaner" with respect to mercury than uncontrolled sub-bituminous coal. This is just one reason Pennsylvania opposes the federal mercury rule. The other is that the federal Clean Air Act expressly prohibits trading for toxics like mercury; however, EPA's mercury rule allows it.

Unlike other air contaminants that disperse broadly, much mercury concentrates locally, creating toxic "hot spots" of contamination. Recent EPA-funded research showed that nearly 70 percent of the mercury collected at an Ohio River Valley monitoring site originated from nearby coal-burning industrial plants. Other studies have had similar findings.

Although Pennsylvania is a strong proponent of trading and other market mechanisms in the appropriate context, allowing such a program for this highly toxic pollutant compromises the integrity of trading and jeopardizes its legitimate use as an effective tool to achieve cost-effective reductions when used in appropriate situations.

Pennsylvania's state-specific rule presumes compliance for any existing electric generating unit combusting 100 percent bituminous coal and using the air pollution control technologies mandated by the Clean Air Interstate Rule. Emissions trading is prohibited, ensuring greater mercury emissions reductions in the commonwealth -- at least 90 percent by 2015. EPA's rule calls for coal-fired utilities to reduce mercury emissions by 70 percent by 2018. But because it allows trading, the federal rule fails to guarantee we would see even a single ounce of mercury reduction in Pennsylvania.

The commonwealth's rule also is a cost-effective approach to mercury reduction. Not only does the state-specific plan follow the same timeline as the two-phased federal CAIR standard; it also enables utilities to realize the co-benefits of mercury reduction through the installation of CAIR-required control technology. Mercury-specific controls are not required.

To comply with CAIR, which is designed to reduce nitrogen oxide and sulfur dioxide emissions, coal-fired plants will have to install selective catalytic reduction systems, electrostatic precipitators and wet scrubbers on their coal-fired units.